About EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting system created by NAVEX enabling management and employees to work together to address fraud, abuse, and other misconduct in the workplace while cultivating a positive and ethical work environment.

Why do we need a system like EthicsPoint?

  • Our employees are our most valuable asset. By creating open channels of communication, we promote a positive work environment maximizing productivity and human potential.
  • An effective confidential reporting system augments our other efforts to foster a culture of integrity and ethical decision-making.

Reporting – General

May I report using either the Internet or the telephone?

Yes. EthicsPoint enables you to file a confidential, anonymous report via either the telephone or the Internet.

What types of situations should I report?

The EthicsPoint system allows employees to report:

  • Unethical Financial Matters
  • Conflict of Interest
  • Violation of Federal/State/Local Laws
  • Violation of Peckham’s Code of Ethics and Conduct

If I witness or have knowledge of a violation, shouldn't I just report it to my manager, security, or human resources and let them deal with it?

If you observe or have knowledge of an incident or behavior violating our code of conduct, we encourage you to report it.

Ideally, employees should bring any concerns forward to their Vocational Service Specialist (VSS), Supervisor, or Human Resources. We do, however, recognize there may be circumstances when employees are not comfortable reporting the issue in this manner. It is for such circumstances we have partnered with NAVEX.

We would rather employees report anonymously than keep the information to themselves.

Why should I report what I know? What’s in it for me?

We strive to work in a positive and flourishing environment, with that prospect comes responsibility to act in an ethical manner. We rely on our employees to notify the appropriate people (Vocational Service Specialist (VSS), Supervisor, Human Resources) if unethical incidents or behavior are occurring. By working together, we can maintain a healthy and productive work environment.

Corporate misconduct can threaten the very existence of an entire company.

Does management really want me to report?

We certainly do. In fact, we need employees to report. Reporting can minimize the potential negative impact on the company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPointsecure server. NAVEX makes these reports available only to specific individuals within Peckham, Inc. who are charged with evaluating the report. All report recipients have had training in handling these reports in a confidential manner.

Isn’t this system just an example of someone watching over me?

We have carefully chosen the best reporting tool to meet our compliance obligations. One in which allows us to ensure a safe, secure, and ethical workplace. Effective communication is critical in today’s workplace, and this tool enhances communication.

Reporting Security & Confidentiality

It is my understanding any report I send from a company computer generates a server log showing every website my PC connects with. Won’t this log identify me as the report originator?

NAVEX does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside our work environment (such as one located at an Internet café or at a friend’s house) through the EthicsPoint secure website. Many people choose this option, as NAVEX’s data shows fewer than 12% of reports are generated during business hours.

Can I file a report from home and remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal remains secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses, so anonymity is completely maintained.

I am concerned the information I provide EthicsPoint will ultimately reveal my identity. How can you assure me this will not happen?

The EthicsPoint system protects your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure the body of the report does not reveal your identity by accident. For example, “From my cube next to Jan Smith…” or “In my 33 years…”

Is the telephone toll-free hot line confidential and anonymous too?

Yes. You are asked to provide the same information you would provide in an Internet-based report and an interviewer types your responses into the EthicsPoint Web site. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report to identify yourself if you wish.

Tips & Best Practices

I am aware of some individuals acting unethically, but it doesn't affect me. Why should I bother reporting it?

All unethical conduct, at any level, ultimately hurts the company and all employees, including you.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

File a report. NAVEX can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The EthicsPoint system and report distribution ensure implicated parties are not notified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if Peckham, Inc. has further questions for me concerning my report?

When you file a report at the EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique, randomized number called a “Report Key” and are asked to choose a password.

You can return to the EthicsPoint system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a Peckham representative.

We strongly suggest you return to the site in the time specified to answer company questions. You and Peckham, Inc. now have entered an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

Are these follow-ups on reports as secure as the first one?

All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

What if I lose my Report Key or forget the Password I created?

To ensure security and confidentiality is maintained, if you lose your report key or password, you will need to file a new report. Mention in the new report it is related to a report or question you previously submitted.

Can I still file a report if I don’t have access to the Internet?

If you don’t have access to the internet or are uncomfortable using a computer, you can call the EthicsPoint toll-free hotline, which is available 24 hours a day, 365 days a year.